Johnson v. Commissioner
United States Tax Court
43 T.C. 736 (1965)
Helene C. Johnson (plaintiff) owned a farm property that she leased to a riding club. The farm property was condemned through eminent domain by the Cleveland & Pittsburgh Railroad Company. Johnson used the proceeds from the condemnation to purchase land in Cleveland, Ohio, that she leased to the Standard Oil Company to use for a gas station. Johnson did not report the condemnation award as a taxable gain. Instead, Johnson argued that § 1033 of the Internal Revenue Code allowed her to avoid recognizing the gain because she used the proceeds to purchase a replacement property that was similar or related in service or use. The Commissioner of Internal Revenue (the Commissioner) determined that the replacement property was not similar or related in service or use. Johnson appealed.
Rule of Law
Holding and Reasoning (Dawson, J.)
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